March 11, 2008
Dear Ms. Morris
I appreciate the opportunity to comment on the SECs proposal to delay implementation of Section 404(b) of Sarbanes- Oxley Act (SOX) for non-accelerated filers, as well as the important initiative to study SOX 404.
Sarbanes- Oxley Acts purpose is to provide investors with reliable financial reporting through internal control. I recommend that it is compulsory for the non- accelerated filer to include an auditors attestation report on ICFR.
However, I support Securities and Exchange Commission (SEC) proposal to delay for an additional year the implementation of Section 404(b) of the Sarbanes-Oxley (SOX) Act of 2002 for non-accelerated filers.
It is important that the requirement of the Sarbanes- Oxley Act be cost effective for the small reporting companies. I believe that a delay for at least another year will help the smaller public companies implement SOX 404
An additional one-year deferral of the auditor attestation report required for smaller public companies would help them avoid unnecessary compliance cost. I anticipate that the proposal study will find that the cost of implementing SOX 404 are falling and will allow small public companies to regain their full status in 2010 by not allowing on future deferral of SOX 404 implementation.
To conclude, I strongly believe that a delayed for Small reporting companies is essential. The proposal of delaying Section 404 another year is necessary